Nigel,

I'll give it a shot:


Within its Mission and in its operations, ICANN will respect internationally recognized Human Rights.  ICANN would be obligated to respect internationally recognized Human Rights, but only to the extent consistent with its mission.  Respect might be defined at least in part according to the Ruggie principles, i.e., avoid infringing on the internationally recognized human rights of others), but that is going to require work in Work Stream 2.  Again, if we use Ruggie, "internationally recognized Human Rights" would mean "at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work."  The reference to the ILO Declaration shows a bit of a mis-fit with ICANN as a business enterprise, since Ruggie is aimed primarily at business's relationship with employees, supply chain, etc., and may not fit so well with an organization whose "product" is technical coordination and the implementation of global policy set by non-employee stakeholders.  So this might be good for ICANN's overworked policy staff!  Of course, that is a Work Steam 2 discussion....

This commitment shall not in any way create an obligation for ICANN, or any entity having a relationship with ICANN, to protect or enforce Human Rights beyond what may be required by applicable law. The key here is that it does not "create an obligation" for ICANN.  In other words, it doesn't add any new "protection or enforcement" obligations for ICANN.  However, there is nothing in this language that is in any way preventative, nor does it take away (or "relieve") any obligations ICANN may have -- whether in law, ICANN policy, or in contract.  As such, it does not prevent ICANN from choosing to do anything within its mission that could be viewed as protecting or enforcing Human Rights regardless of whether its part of applicable law. (I'll save my response on the "applicable law" discussion for a different email.)  This sentence also acknowledges that ICANN does have an obligation to follow all applicable laws (including those that protect Human Rights).  Ruggie classifies "protecting" and "enforcing" as inherent the powers (and duties) of government, not of a private company.  In explaining "protecting" Human Rights, Ruggie refers to a duty to "prevent, investigate, punish and redress [Human Rights] abuse through effective policies, legislation, regulations and adjudication." This implies that "protecting and enforcing" is not merely doing something that might qualify as protecting, enforcing or preventing, etc. Human Rights; it is using the power of the state to do so. (The rest of the Ruggie definition is even more oriented toward what states can do.)  Of course, a private company can (and should) try to "prevent [Human Rights] abuse" in its workplace "through effective policies."  If I follow Ruggie's logic, that would still be considered "respecting" Human Rights and not protecting or enforcing Human Rights.  As such, if you follow Ruggie literally, it could be said that ICANN (not having the power of the state) could not "protect or enforce" Human Rights even if it tried.  Of course, ICANN has powers that are different from those of a typical "business enterprise."  And "protect and enforce" can be construed more broadly than Ruggie does, so that things businesses do could be called "protecting" and "enforcing."

In particular, this does not create any additional obligation for ICANN to respond to or consider any complaint, request, or demand seeking the enforcement of Human Rights by ICANN. This is intended to insulate ICANN from claims that the new Bylaw creates a new job for ICANN -- Human Rights "enforcer."  Again, ICANN could "enforce" Human Rights, if it chose to do so, and if you don't read "enforce" so narrowly that it is only the power of a sovereign state. (If you do read "enforce" narrowly, ICANN couldn't "enforce" anything even if it tried, since it is a private entity -- but that gets us back to the issue that ICANN is not a typical "business enterprise".)

This Bylaw provision will not enter into force until a Framework of Interpretation is developed as part of “Work Stream 2” by the CCWG-Accountability or another Cross Community Working Group chartered for such purpose by one or more Supporting Organizations or Advisory Committees. One could say this means the Bylaw is merely symbolic, and does nothing until the FoI is developed and adopted, and is itself "in force."  However, it does a little more than that, for better or worse -- it creates a presumption that the particular words of the Bylaw are the rights words for the Bylaw, regardless of where Work Stream 2 takes us.  So, if the work of the CCWG-WS2 concludes that these words have "issues" and we'd all be better off with variations, additions, subtractions or wholesale changes, it will be a bit of an uphill battle to remove the "not-yet-in-force-but-already-adopted" language and replace it with "new and improved" language.  It may also tend to force WS2 to try and deal with these words and make the best of it, rather than coming out at the end of the process with both a FoI and a matching bylaw. But c'est la vie....

ICANN shall support the establishment and work of such a Group to facilitate development of the Framework of Interpretation as promptly as possible.  To paraphrase Warren Zevon, "Give us lawyers, guns and money."


Hope that helps, and is not too stultifying.  Some may disagree with some of what I've said, but hey! that's what Work Stream 2 is for.  

[I should add that the usual caveat applies, as it always does (this is not legal advice, this does not form a lawyer-client relationship, (but feel free to send money), etc.).]

Greg



On Thu, Jan 28, 2016 at 12:59 PM, Nigel Roberts <nigel@channelisles.net> wrote:
MAYBE, just maybe, we can put this to bed.

Can you construe (deconstruct) the latest language for me, the way you see it, please?

As an aside, whilst I have no issue with the word enforcement, since ICANN will not employ blue helmets, I am not sure that IP interests would be that keen on relieving ICANN of its obligation to protect the right to property (on matters properly within mission).

On 28/01/16 17:51, Greg Shatan wrote:
Nigel,

I have to disagree with your interpretation of the proposed bylaw.  The
"applicable law" restriction only applies to ICANN's obligation (if any)
to "protect" and "enforce" human rights.  It does not apply to ICANN's
obligation to "respect" human rights.  As such, ICANN would be required
to take into account human rights from the posture of "respecting" them.

What exactly does that mean?  Well, that's what will be determined in
WS2.  Avri believes that it would include a human rights impact
assessment.  Is she right?  Wait for WS2.  Some think the Ruggie
Principles should apply, while others believe that there are significant
problems with that idea.  Who is right?  Wait for WS2.  Is this intended
to change how ICANN operates (including policy development) or is just a
backstop to prevent ICANN from backsliding from its current level of
commitment (arguably enforced by the NTIA relationship)?  Wait for WS2.
Are sequels better than the original or do they tend to be
unimaginative, bloody and trite?  Wait for WS2.

Greg

On Thu, Jan 28, 2016 at 12:38 PM, Nigel Roberts <nigel@channelisles.net
<mailto:nigel@channelisles.net>> wrote:

    But do you want a cleverly drafted by-law that guarantees that human
    rights are not required to be taken into account (whilst appearing
    to say the contrary), or a word-is-my-bond committment from the
    current Board, who are at least, a lot more trustworthy than some
    Boards that there were heretofore?

    You can only pick one.


    On 28/01/16 17:25, Avri Doria wrote:

        Hi,

        The problem with a firm commitment by the Board is that it
        something
        that can be undone or changed by a future Board with ease and at
        their
        will.  Unlike a bylaw which involves a multistakeholder process.

        Without the bylaw, there is no guarantee.

        avri

        On 28-Jan-16 11:21, Kavouss Arasteh wrote:

            HR should be referenced in intermediate Bylaws and drafted
            at WS2. Based on our dis discussions and REC . once FOI is
            ready the final legal  text shall  be approved and included
            in the Definitive Bylaws. In the meantime Board,s firm
            commitment once approved by CCWG shall apply
            Kabouss .

            Sent from my iPhone

                On 28 Jan 2016, at 16:33, Avri Doria <avri@acm.org
                <mailto:avri@acm.org>> wrote:



                    On 28-Jan-16 09:25, Andrew Sullivan wrote:

                        On Thu, Jan 28, 2016 at 02:05:26PM +0000, Nigel
                        Roberts wrote:
                        ICANN must simply respect human rights. That's it.

                    I wish I knew what this is supposed to mean for
                    ICANN action, though.
                    I'm trying to imagine something where ICANN would
                    act differently in
                    the presence or absence of the bylaw, and I've been
                    unable to come up
                    with anything.

                As I have mentioned before, for me the prime issue is
                that human rights
                impact analysis be done as part of the PDP process as
                opposed to just
                waiting to see if some government agency slaps our wrist
                afterwards for
                not having considered the impact of, e.g., freedom of
                expression or an
                open internet.  At this point we just do stuff and then
                wait to see if
                NTIA, or any other federal agency, or the GAC lets us
                know that we have
                messed up.  Requiring that we respect Human Rights
                includes it being in
                scope as a consideration that is understood and
                discussed when policy is
                made and considered for approval.

                Without the bylaw such considerations remain out of
                scope in a future
                where there is no backstop for our actions.   i believe
                that taking on
                this responsibility is our only reliable response to the
                NTIA
                requirement.  And I believe that the fears of such a
                bylaw have been
                shown to be emotional and not fact based.



                    (That's also, I suppose, why I don't really have an
                    opinion about what ought to be done here, except
                    that we should come
                    to a speedy conclusion so that the document can ship
                    and we can get
                    the transition over with.)

                I see this as a gating issue.

                Though I do not think our work can ever be called
                speedy, even if we
                were to reach consensus this week.
                And this is just the start of the transition, unless you
                also believe
                that implementation and  WS2 are not part of the transition.

                avri

                ---
                This email has been checked for viruses by Avast
                antivirus software.
                https://www.avast.com/antivirus

                _______________________________________________
                Accountability-Cross-Community mailing list
                Accountability-Cross-Community@icann.org
                <mailto:Accountability-Cross-Community@icann.org>
                https://mm.icann.org/mailman/listinfo/accountability-cross-community




        ---
        This email has been checked for viruses by Avast antivirus software.
        https://www.avast.com/antivirus

        _______________________________________________
        Accountability-Cross-Community mailing list
        Accountability-Cross-Community@icann.org
        <mailto:Accountability-Cross-Community@icann.org>
        https://mm.icann.org/mailman/listinfo/accountability-cross-community

    _______________________________________________
    Accountability-Cross-Community mailing list
    Accountability-Cross-Community@icann.org
    <mailto:Accountability-Cross-Community@icann.org>
    https://mm.icann.org/mailman/listinfo/accountability-cross-community